In a recent murder case coming out of a Texas court, the defendant unsuccessfully argued on appeal that the trial court erred in denying his motions to suppress, a portion of the State’s DNA evidence linking him to the murder, and custodial statements made to law enforcement. In 2019, the defendant was sentenced to life imprisonment after entering an open plea of guilty of capital murder. On appeal, the court overruled the defendant’s challenges and affirmed the trial court decisions.
The Facts of the Case
According to the opinion, the defendant was arrested in 2019 for a murder committed in 1974 after the cold case was reopened. While the defendant was a suspect in the initial investigation, he was released after being given a polygraph test. After the case was reopened in 2019, various items from the crime scene were sent for testing at the Serological Research Institute (SERI) for DNA testing. When no matching profiles were found in the FBI database, the DNA profile was sent to a laboratory in Houston for forensic-grade genomic sequencing (FGGS). The FGGS test resulted in a match with the defendant’s profile.
Following the match, detectives conducted a trash run on the defendant’s home, collecting five bags of discarded trash to test for the defendant’s DNA. The DNA collected from the trash of the defendant matched the DNA profile produced by the FGGS DNA profile of items from the crime scene. The defendant was arrested and he admitted to detectives that he committed the murder, revealing the location of the murder weapon in the process.
On appeal, the defendant made five different arguments, including (1) that the FGGS DNA evidence was inadmissible due to the lab lacking accreditation by the Texas Commission of Forensic Science (TCFS), (2) evidence from the FGGS DNA tests was inadmissible due to technicians lacking TCFS licensing, (3) evidence from the FGGS DNA test was inadmissible due to lab work being performed by employees not licensed by the TCFS, (4), the DNA profile created by the trash run was acquired without a proper warrant, and (5) the defendant made custodial statements that were improperly induced by detectives.
The appeals court considered the defendant’s arguments but ultimately disagreed. Regarding the suppression of evidence from the FGGS DNA profile due to a lack of TCFS accreditation, the appeals court found that the work in question merely constituted “batch work” and not “forensic analysis” under the relevant state laws. As a result, the motions to suppress evidence were properly denied by the trial court. On the issue of the defendant’s Fourth Amendment rights being violated by the trash run evidence collection by law enforcement, the appeals court sided with the trial court, finding that the defendant did not have the standing to contest the search, but even if he did, the error would have been harmless. Lastly, in the argument on custodial statements advanced by the defendant, the court found that the detectives did not induce the defendant’s statements with promises of a lighter sentence, pointing out that the statements made were general statements of fact and not promises.
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